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SEC Will Prioritize AI, Cybersecurity, and Crypto in its 2025 Examination Priorities

On October 21, 2024, the US Securities and Exchange Commission ("SEC") Division of Examinations ("Examination Division") announced its 2025 Examination Priorities ("Report"). Investment advisers and broker-dealers should...more

FinCEN Issues Final Sweeping AML Requirements for Registered Investment Advisers & ERAs

On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment...more

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

SEC Lists Crypto and Information Security Among its 2024 Examination Priorities

On October 16, 2023, the US Securities and Exchange Commission ("SEC") Division of Examinations ("Examination Division") announced its 2024 Examination Priorities. Registrants should ensure that policies, procedures, and...more

SEC’s Focus on Off-Channel Communications Continues

On September 29, the US Securities and Exchange Commission ("SEC") brought its latest wave of enforcement actions related to "off-channel communications," charging 10 additional firms with failing to maintain employee...more

Permitted Finder Activities: SEC Proposes Long-Awaited Exemption

Finders seeking to assist companies in raising capital are required to navigate an often cloudy path to determine whether the finder's activities and any compensation the finder would receive for its services would run afoul...more

Broker-dealers should be ready for Regulation Best Interest

In light of recent discussions regarding the content and implications of Regulation Best Interest, Securities and Exchange Commission (“SEC”) Chairman Jay Clayton recently stated that broker dealers should be ready for the...more

Key Takeaways from the SEC and FINRA Joint Statement on Broker-Dealer Custody of Digital Asset Securities

As part of the continuing dialogue with market participants working toward developing methodologies for establishing possession or control by broker-dealers over their customers' digital asset securities, on July 8, 2019, the...more

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